07 October, 2024
Working Group Updates 10/7/2024
07 October, 2024
- TRACE Working Group. The TRACE Working Group discussed the SEC’s recent approvals of the FINRA and MSRB rule filings to reduce the reporting timeframe for trades reported to TRACE and RTRS, subject to exceptions for certain manual activity and firms with limited trading activity. The Working Group discussed the implementation timetable. The Working Group discussed the scenario where a firm has a system issue that prevents automated reporting, and the firm automatically reports after resolving the system issue. The Working Group discussed RTRS providing test symbols.
- OFR Repo Reporting Working Group. The OFR Repo Reporting Working Group reviewed and discussed the FAQ updates published by the OFR on September 27, including updates relating to reporting transactions of subsidiaries, the calculation of outstanding commitments, reporting corrections, the definition of a business day for reporting, reporting on the close date of a repo, and reporting when the close leg of a repo does not settle on the scheduled termination date.
- Short Position Reporting. The FIF Short Sales / Reg SHO / Short Reporting Working Group discussed a recent call with FIF members and SEC representatives relating to the implementation of short position reporting. The Working Group discussed challenges with excluding specific transactions from the gross short position calculation, reporting when an issuer has registered and unregistered classes of securities, and the 2.5% reporting threshold for Threshold A securities. The Working Group discussed next steps with the SEC.
- Regulation NMS Amendments. FIF hosted a call for the Data and Technology and Front Office Committees and the SEC Equity Market Proposals Working Group to review and discuss the Reg NMS amendments recently adopted by the SEC.
- CAT Monthly Update Working Group. The CAT Monthly Update Working Group reviewed guidance and updates from the CAT Plan Participants and FINRA CAT on CAT Transaction Reporting, CAT CAIS and CAT billing during the prior month. The Working Group reviewed the current areas of focus for FIF members and the current open issues for CAT Transaction Reporting, CAT CAIS reporting and CAT billing.
- CAT Transaction Reporting Working Group. The CAT Transaction Reporting Working Group reviewed the EBS survey submitted by FIF to the SEC. The Working Group reviewed FIF’s recent response to FINRA relating to FIF’s exemptive request on representative order linkage. The Working Group discussed the pass-through of CAT fees and a FINRA inquiry relating to OTC securities executed by a firm as principal.
Eduard Kotlyar